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This article analyses the common ownership or control requirement of Section 482. It analyses the common control structure and its proper role in the application of the statute. The author addresses the Tax Court decision, DHL Corp.v.Comr and the Lease Stripping Field Service Advice Memorandums

This article analyses the common ownership or control requirement of Section 482. It analyses the common control structure and its proper role in the application of the statute. The author addresses the Tax Court decision, DHL Corp.v.Comr and the Lease Stripping Field Service Advice Memorandums